CMS Issues More Guidance on Stairstep Kids

By Wesley Prater

As Tricia Brooks highlighted in her previous blog, CMS recently released a set of FAQs to provide more guidance on telephonic applications, MAGI-based eligibility, Medicaid and CHIP eligibility, and the 75/25 Federal matching rate. The FAQs included more guidance about the transition of children ages 6-18 up to 133% of the FPL under a separate CHIP program, aka “stairstep kids,” who will be transitioning to Medicaid by January 1, 2014. I thank CMS for the timing of this guidance because we just released a paper with the Kaiser Commission on Medicaid and the Uninsured and posted a blog about this provision of the ACA.

A few important issues for stairstep kids were addressed in the FAQs regarding this “alignment of eligibility for children” as we, at CCF, like to call it:

  • This alignment is not an option for states.  The stairstep kids fall under the mandatory Medicaid group for poverty-level related kids under section 1902(a)(1)(A)(i)(VII) of the Social Security Act effective January 1, 2014.  However, CMS did note that they are available to work individually with states on their transition plans.
  • States will continue to receive the CHIP enhanced FMAP for the stairstep kids that have to transition to Medicaid. CMS has said this before and they said it again here.
  • In addition to uninsured children, new children ages 6-18 with family income between 100-133% of the FPL with health insurance will qualify for Medicaid coverage as of January 2014. This is important to remember as separate CHIP programs have rules that preclude coverage for insured kids.
  • States that have to align eligibility will need to submit both a Medicaid and CHIP State Plan Amendment (SPA). States can find the SPA templates here and CMS indicated that they are available to work with states individually and provide technical assistance to states with their transition.

CMS also made the following points for states to ensure a smooth transition for children and families – some of which are similar to issues we raised in our paper:

  • Notify families in a timely matter. This would include informing families on changes related to plans, providers, cost sharing, benefits, and what they will need to do to prepare for the transition.
  • Educate and notify stakeholders, including providers and managed care plans, and carve outs, such as mental health or dental services.
  • Establish a help line for any questions that families may have.
  • Think about continuity of care for children in treatment, such as the transfer of prior authorization requests from CHIP to Medicaid providers.

Aligning eligibility for children is a sound policy, but we learned from our Kaiser paper that this is no small administrative task for states.  States should be proactive and follow these suggestions made by CMS, making it an easier transition for children and families.

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